CBP has revised its informed compliance publication regarding Reasonable Care to include a section regarding forced labor. Additionally, seafood and apparel industries appear to be recent targets of CBP Requests for Information CF28’s regarding forced labor in their supply chain. Although admittedly, the CF28s may also be as a consequence of the passage of the Countering America’s Adversaries through Sanctions Act (CAASA). P.L. 115-44. CAASA created a presumption that “significant goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part by the labor of North Korean nationals or citizens” are forced labor goods and prohibited from entry into the United States.

The seven fact sheets available on CBP’s website are:

• OECD Due Diligence Guidance
• Repeal of the Consumptive Demand Clause
• Q and A: Repeal of the Consumptive Demand Clause
• Forced Labor – Points of Contact
• Forced Labor Procedures
• Forced Labor – Importer Due Diligence
• Forced Labor Detained Shipments

Companies should evaluate their supply chains to insure that they are not at risk. For more information please contact Jeff Snyder or Frances Hadfield.